The court denied defendant's motion to transfer venue from the Eastern District of Texas to the Eastern District of North Carolina, noting (i) "the Eastern District of Texas is a centrally located venue . . . [t]he sources of proof in this case are many and are spread across the nation. . . . [w]hile transfer to North Carolina would make access to some proof easier, this Court is not convinced that access to all evidence would be so," (ii) "a transfer from one district without absolute subpoena power to another without absolute subpoena power is not clearly more convenient—such a transfer will merely reallocate inconvenience to the transferee district," (iii) "the central location of the Eastern District of Texas in relation to this nationwide suit makes it, at the very least, as convenient a location as North Carolina," and (iv) "[b]ecause this case is nationwide in scope, each factor is either neutral or does not weigh in favor of transfer . . . [a]s such, Defendants have not clearly demonstrated that transfer is appropriate."
Novartis Vaccines and Diagnostics, Inc. v. Hoffmann-La Roche Inc., 2-07-cv-00507 (TXED February 3, 2009, Order)